Legal identification

DOCUMENT CONTROL

Function of this Annex. All four instruments of the Framework refer to this sheet for the specific identification of the Data Controller. Its publication and upkeep is a condition of the Framework's enforceability vis-à-vis data subjects and supervisory authorities. This Annex is updated without any need to amend the published instruments whenever a new Adhering Entity joins or an identification detail changes.

1. Site operator and Data Controller

Valencia Holding Group LLC is the Group's Parent Company, the issuing unit of the Digital Legal Framework and the entity operating the corporate site https://vhg.capital. In that capacity it is the Data Controller for personal data collected through that site.

Regarding the address for service. The VHG Group publishes its jurisdiction of domicile and expressly designates the mailbox info@vhg.capital as the formal channel for receiving notices, requests from authorities and requests to exercise data subject rights. The registered agent's full physical address is held in the internal register and is supplied to any authority, or to any data subject demonstrating a legitimate interest, upon request through that channel.

2. Adhering Entities

The following companies are Group subsidiaries and become subject to the Framework upon executing the Deed of Adhesion in Annex E. Each is an autonomous Data Controller in respect of the databases whose purposes and means it determines.

Illustrative character. This list is not exhaustive. Any other affiliate, subsidiary, company, brand or business unit that may in future join the Group, be incorporated by it, or come under its direct or indirect control — within the meaning of Article 261 of the Colombian Commercial Code — joins the Framework by executing the Deed of Adhesion, requiring only an update to this sheet and no amendment to the published instruments.

3. Group Data Protection Office

4. Intellectual property — registration status

Warning. Colombia and the Andean Community operate an attributive system: the exclusive right to a trademark arises from registration, under Article 154 of Andean Decision 486 of 2000. Publicly asserting an exclusivity not yet constituted exposes the Group to a claim of misleading representation. This sheet is updated upon the grant of each registration.

5. National Database Register

The Data Protection Office verifies this table annually, within one month of approval of each entity's financial statements, in accordance with section 16 of instrument MLD-04, and documents the verification whether or not the threshold is exceeded.

6. Processing destinations and international transfers

The VHG Group carries out no transfers or transmissions to jurisdictions not declared adequate. Enabling any flow to a different destination requires the Data Protection Office's prior documented verification of its basis, in accordance with section 13 of instrument MLD-04.

7. Updating this sheet

This sheet is updated, without any need to amend the published instruments, whenever: a new Adhering Entity joins; an identification detail of any entity changes; a trademark registration is granted or refused; an entity exceeds the RNBD threshold; or a new processing destination is enabled.

Updating is the responsibility of the Group Data Protection Office, which records the date and reason for each change.

END OF ANNEX A

Valencia Holding Group — VHG Group Digital Legal Framework Annex A — Entity Identification Sheet | Version 1.0 | Governing language: Spanish